Civic Ethnic NationalismIntroduction
Whether the two 19th century models of Civic and Ethnic nationalism can be used as a route for understanding 20th century notions of citizenship and national identity is debatable. In our globalised world it has become harder for countries to maintain a sense of collective solidarity within their borders as not only are these threatened by regionalism on the one hand but also by cosmopolitanism on the other.
Thus creating a sense of national identity by employing ethnic ideas would not only be ineffective, as it would exclude many communities within countries who would not describe themselves as ‘ethnically’ affiliated with the nation, but also dangerous as it highlights already existing divides between ethnic groups. The alternative, which would be to promote a civic idea of nationhood, is also unsatisfactory as it is lacks the personal side of cultural attachment that is found in ethnic nationalisms.
Although the analytical distinction between ‘civic’ and ‘ethnic’ models of nationalism is useful for understanding debates about citizenship and national identity because of its relevance to immigration policy, civic and ethnic nationalism are not as distinct as the debate would suggest. Theorists such as Anthony Smith and Hans Kohn propose the dichotomy of ethnic and civic nationalism to different degrees.
Ethnic nationalism is broadly defined as eastern type nationalisms, such as German, Russian and Indian. It is traditionally seen as being illiberal and backward looking as it is based on a common idea of descent, language and religion. Conversely, civic nationalism is seen as being rational and voluntaristic and is associated with the west, in particular France, and seen as being more forward looking.
The dichotomy between civic and ethnic nationalism is clearly open to debate as the United Kingdom, seen as a civic society, has problems related to ethnic nationalism such as racism. One need only remember the Cantle report which concluded that “an act of national allegiance from immigrants might help further race relations” and that “a meaningful concept of citizenship” must be created, to realise the long way Britain has to go to become an integrated society.
What is notable is that the answers to the race riots crisis all seemed to be found in civic ideas of nationhood. In the nineteenth century it was the ethnic and not the civic idea of the nation that was most predominant in Europe. Krishan Kunmar writes “This was largely because there were so many nations without independent statehood, at a time when becoming an independent nation-state was the key to efficient modernisation and industrialisation. Lacking a state, one was forced to put ones claims as a legitimate nation in cultural, not political terms.”
The concepts of National Identity and Citizenship also have a widely contested relationship much in the same way as ethnic and civic nationalism. The orthodox view, propounded by historians such as Ernest Kohn, states that nationality and citizenship are basically antithetical and that modern societies are seen as those in which people are bound to the state as social-political actors rather than cultural-ethnic beings.
 According to Jurgen Habermas, the very concept of National Identity adapts itself gradually to the affirmation of Citizenship. However, Anthony Smith seems to believe that National Identity is not yet completely absorbed or overcome by Citizenship and is therefore still intrinsically present in ethnic consciousness. Thus the question is whether Citizenship or National Identity comes first, whether the collective consciousness of a people is an organically formed notion or whether it is the result of top down policy.
Since the 1992 Maastricht treaty established European citizenship, there has also been a heated debate on whether it will eventually replace national citizenship in the EU (EU) member states. Some scholars are exploring a new citizenship model called transnational citizenship, trying to find a way to extend citizenship rights to non-citizens or beyond the territorial borders of the state. So what is the result of European unity in terms of citizenship and transnational identity? What will become of the nation-state in view of this and in light of regions which are asserting their autonomy?
To deduce whether, in today’s Europe, the analytical concepts of ethnic and civic nationalism are still relevant this essay will use Germany and the United Kingdom (UK) as practical examples. Despite having taken place in two different geographic regions and having significantly different histories, the countries of Germany and the UK do invite comparison; they not only share a imperial history but were both forced to deal with an influx of immigrants in the second half of the 20th century which changed the demographics and effected citizenship laws and national identity.
Citizenship Debates in Germany and the UK
In his book, Citizenship and Nationhood in France and Germany, Rogers Brubaker employs the basic distinction between civic and ethnic nationalism to explore how differing traditions of nationhood have shaped and sustained different conceptions of citizenship among the French and Germans.
He notes that the idea of an absolute civic or ethnic nationhood does not exist and shows the extent to which differences of policy and attitude derive from radically different understandings of what constitutes the nation. “The German definition of the citizenry as a community of descent, restrictive toward non-German immigrants yet remarkably expansive toward ethnic Germans from Eastern Europe and the Soviet Union reflects the pronounced ethno-cultural inflection in German self-understanding.”
Conversely, the UK is first and foremost a political community. Krishan Kunmar says the UK “puts stress on willed, active citizenship, and on civic participation. Foreigners can join provided only that they fulfil the residential and civic requirements of membership.” This is because the UK is a multination state and in light of this has had to adapt to a more civic basis for in order to facilitate integration. Where Germany operates on a citizenship law based on Jus Sanguinis, the UK operates using that of Jus soli. This contrast in their basic tenets is clearly illustrated in the granting of citizenship to immigrants. But how absolute are these apparent differences between the UK and Germany?
Germany’s Citizenship Laws
Germany was forced to deal with an influx of over 1.5million immigrants between 1988 and 1995, attracted by their liberal asylum policy compared to other European states and due to the end of the cold war in 1989. Article 16(2) of the 1949 Federal constitution stated that ‘All persons persecuted for political reasons enjoy the right of asylum.’ This is generally taken as assign of remorse at the actions of previous German governments.
This influx of immigrants and its reporting by the press caused social tensions and played some role in the outbreaks of racial violence in the late 1990s. Media attention and violence eventually spurred politicians into action, resulting in a modification of Article 16 (2) of the federal constitution in 1993. Nevertheless Germany remains the most generous asylum country in Europe. In an attempt at creating a unified feeling of Germany throughout the iron curtain period, the Federal Republic drafted the 1949 constitution.
Article 116/I which stated that those people of German origin remaining in eastern European states, including the USSR, after the post-war settlement could move to the federal republic, they were referred to as Aussiedler in German. These Aussiedler however, also encountered hostility as many spoke little German and had little in common with German culture. Eventually they too encountered tightening of laws which resulted in a decline of 2,267,000 Aussiedler moving to Germany between 1988 and 1996 to 178,000 in 1996. 
Until a new Citizenship law in 1999, Germany’s principle of Jus sanguinis dating back to 1913 meant that people born in Eastern Europe who could demonstrate German ancestors had greater rights than second, third, fourth or any generation of Turks, Greeks or Italians born on German soil. The centre and left of the political spectrum exerted intense pressure on local and national governmnet to integrate long-term resident aliens into German society, and under this pressure, and lacking the means to force most foreigners in the country to leave, the national government revised the citizenship law.
In amendments adopted in 1990, 1993 and 1999 it granted long-term residents a right to naturalisation and gave their children German citizenship at birth, although in both cases it imposed conditions designed to prevent dual citizenship. The original proposal by Schroeder’s government to automatically grant dual citizenship was modified after pressure from the Christian Democrats and electoral setbacks.
Now children born in Germany to legal immigrants with eight years residence and underage children residing five years with at least one parent holding unlimited residence receive German citizenship but must decide between age 18 and 23 if they want to continue it. Multiple nationality is only permitted if the country of origin poses unreasonable conditions or does not release an applicant’s petition on time. The debate surrounding whether Germany should allow dual citizenship is testament to the fact that Citizenship can never solely inhabit the political realm of thought and is often an inherent part of someone’s self-definition.
An example is Ali Kambaroglu who runs a grocery shop in northern Berlin, one the eve of the new law he said “I feel like a German, but I still feel Turkish when I’m in Turkey.” He arrived in Germany from Turkey 20 years ago and, after years of frustration at high taxes and no vote, he decided to become German But to do that had to, reluctantly, give up his Turkish citizenship. 
Thus as a result of changes in the character of immigration the 1990s fundamentally altered Germany’s attitude and policies towards immigration and who could be considered German. This illustrates the dynamic nature of the idea of nation and the problem with using such absolute concepts as ethnic and civic nationalism as clearly Germany is neither one nor the other but a hybrid of the two from a legal-political point of view.
The UK’s Citizenship Laws
As opposed to Germany’s ethnic preponderance, the UK is often seen as a prime example of political nationhood. The UK is also, unlike Germany, comprised of different nations whose statehood comes under the umbrella of Britishness. British ‘subjects of the crown’ only became ‘Citizens of the United Kingdom and Colonies’ under the 1948 nationality act. Following the docking of the Empire wind rush in Britain and the 500 immigrants on board a Cabinet memorandum circulated on 18 June 1948, Creech Jones, the Colonial Secretary, stated that ‘[i]t will be appreciated that the men concerned are all British subjects. The government of Jamaica has no legal power to prevent their departure from Jamaica and the government of the UK has no legal power to prevent their landing.' Unlike other commonwealth countries Britain did not create a citizenship of its own at this point.
Britain’s openness led to an unexpected number of colonial immigrants to the UK who soon became citizens. This led to a redefinition of British nationality. Until the 1960s and 1970s the UK retained a rather loose and non-ethnic sense of Britishness in order to encompass post-imperial peoples. The passing of the Commonwealth Immigrant’s Act 1962 and the Immigration Act of 1971 then placed limits on their freedom of entry to the UK. Finally the 1981 legislation created British citizenship.
It automatically attributed Jus soli to children born in the UK to a British citizen or non-British permanent resident born in the UK; otherwise a minor could attain British citizenship if resident in the UK for 10 continuous years before applying. In addition British citizenship is automatically attributed through Jus sanguinis to the first generation born abroad. The 1981 legislation was subject to much controversy over its abandonment of jus soli as the new act no longer allowed those who should not have been residing in the UK- illegal entrants or overstayers-or those who were temporary residents-short-term visitors or students-to secure British citizenship for their children born in the UK.
The government claimed that , provided the traditional Jus Soli, which had originated from the notion of allegiance to the sovereign of the territory of one’s birth, continued, ‘British Citizens so created…would form a pool of considerable size, and they would; have little or no real connection with the UK.’ By adding the principle of Jus sanguinis, therefore, the act was supposed to link British citizenship with a close affiliation with the UK, arguably, a sense of ‘Britishness.’
Unlike Germany, there are no restrictions on dual citizenship in the UK. The reasons for most countries disallowing dual citizenship is because they have an active idea of citizenship. There a many reasons why Germany does not allow dual citizenship except in very few circumstances. One is that they have military service, put in place to ensure that the military is not only comprised gung-ho members of the country and is a liberal force.
This means that should someone be a citizen of another country they could evade this service. It also ensures ethnic diversity in the military and this again curbs potential uniformity of beliefs and preponderances within the military. Therefore Germany’s opposition to dual citizenship is primarily based on liberal grounds but this nevertheless has the effect of excluding many gastarbeiter, or guest workers, who wish to retain their original citizenship.
The UK does not have compulsory military service, nor does it have the history of Germany and the consequent limitations put on its military because of this history. By allowing dual citizenship, the UK has encouraged multiculturalism. But this has also had the effect of creating a number of citizens who would not necessarily see any allegiance, other than for purely practical political reasons, to Britain.
It is important to look at the rights of non-citizens. Formal citizenship is not necessary to vote in a British local election. EU and commonwealth citizens can vote in the Scottish parliamentary or Welsh national assembly elections and European parliamentary elections. Where citizenship can be a way of defining ones political/civic relationship to a country, in the case of Britain, it is possible to assert ones civic identity regionally by merely being a legal immigrant.
Germany however does not have alien suffrage and although for a brief moment in 1989 three German Laender allowed alien suffrage the Federal Constitutional Court ruled these rights unconstitutional a year later. Arguably these differences in rights for non-citizens can be explained by the historically divergent conceptions of citizenship and democratic legitimacy. This can most clearly be seen in the case of Germany where, as we have seen, there has been an emphasis on nationality and ethnicity rather than on residence. Although their asylum laws suggest differently as they are based on civic elements.
Therefore we have seen that citizenship is used as a form of immigration control. In the UK the turn from Jus soli to incorporating ideas of Jus Sanguinis came about because allowing all ex-British colonies the right to British citizenship could have potentially meant chaos for the population count. It was also seen as a threat to ‘Britishness’ as politicians and the public felt this sense of collective identity would be lost amongst so many immigrants who felt little allegiance to the nation.
For Germany however, the continuation of the outdated principle of Jus Sanguinis was more ideological. Germany’s generous asylum laws created the problem of a huge number of immigrants living in Germany, despite this the Federal Republic refused to call it a land of immigration, reflecting, perhaps, an ethnic idea of national identity at the time.
National Identity Debates in UK and Germany
National Identity is a difficult subject to quantify as it attempts to define the collective conscious of an entire nation and because of this often loses sight of minorities. It is also a highly debated subject and is becoming more so in the globalised world which threatens the idea of sovereign nations.
Historians such as Mary Fulbrook dispute the concept of an essential national identity: “The construction of national identity inevitably faces challenges and has to change in a context of increasing population mobility, the dramatic expansion of communication systems and the readjustment of the functions of regions, states and inter- or transnational organisations in a changing global context.” Nowadays countries are forced to encompass peoples of differing loyalties all under their one umbrella. In the face of this challenge to integrate these different people it has become necessary to encourage a more civic based nationalism. But to what extent is this possible? Can a national identity be based solely on political institutions?
As discussed there is a debate over whether it is national identity which sets the course for citizenship rights or citizenship rights that create a particular national identity. There is also the question of whether any country does in fact have a collective national identity, and whether, depending on the country, it is moulded by citizenship and shared civic institutions i.e. a civic form of nationalism or a shared language, history, culture and religion i.e. an ethnic nationalism.
When looking at debates about national identity in Germany it is vital to take into account Germany’s recent and significant past; the Holocaust, its post-war division spanning 40 years and final reunification. Thus contemporary debates surrounding German National identity are whether it has a single national identity to speak about and in what terms.
The UK is also a complex and interesting case as there are many levels to it, as Robin Cohen states:
British identity shows a general pattern of fragmentation. Multiple axes of identification have meant that Irish, Scots, Welsh and English people, those from the white, black and brown commonwealth…have had their lives intersect with one another in overlapping and complex circles of identity construction and rejection. The shape and edges of British identity are thus historically changing, often vague and to a degree malleable-an aspect of the British identity I have called the ‘fuzzy frontier’.
This again begs the question of whether there is in fact one British national identity to speak about or many more and on different levels.
In addition to these countries’ fragmented identity deriving from their own histories both countries have had to incorporate a significant number of immigrants into their territories over the past half century and this has affected the way in which they think about national identity, thus multiculturalism has further fragmented the sense of national identity. European integration is further obscuring the debate about national identity.
Germany’s National Identity
A significant question is whether the outdated law of Jus Sanguinis and its continued use in German Citizenship law until 1999 is evidence of a powerful continuity in national self-understanding, one that still defines Germanness in ethnic terms and excludes anything un-German. According to Hoffman the extraordinarily long life of the legal institution of Jus sanguinis formed the legal basis for the unity of the nation in the face of post war division. “The logic of Jus Sanguinis has…insured that the self-understanding of the federal republic would remain as a “non-immigrant country.”
It was only in the 1980s, in the face of economic stagnation and long-term unemployment that a public debate about national identity and immigration emerged. By this point the immigrant population had risen significantly, in the 1950s it was 80 000 and in 1960 over 1.3 million.
Heinz Kuhn, the first Federal Commissioner of Immigration Affairs said, in a 1979 memorandum, that the situation of having so many foreigners and their families living in the Federal German Republic (FDR) was a “development that is no longer reversible…the majority of those in question are no longer ‘guest’ workers’ but immigrants for whom a return to their original countries is no longer a consideration for many different reasons.” This led to higher social tension in the larger cities and resulted in the first overt attacks against foreigners. In these circumstances many sought to end immigration based on ethnic arguments. “Cultural pluralism was rejected since national identity continued to be defined in terms of a Volk unified by a common language, history and culture.” 
Fragmentation of national identity can be seen in acts of racism. In the first couple of years after unification Germany saw a resurgence of right-wing racism expressed in acts of violence against immigrants, asylum seekers, long-term resident gastarbeiters and other apparently ethnic ‘others’. This also demonstrates the ‘ethnic’ terms on which some Germans based their nationalism at that point in time.
Arguably this was due to the ethnic terms in which the Federal German Republic (FDR) defined Germans by offering any ‘ethnic’ Germans full citizenship rights-whether from the German Democratic Republic (GDR) or further afield- in an attempt to make the idea of German unity endure. Thus this meant, as Christhard Hoffman puts it, that “cultural pluralism was rejected since national identity continued to be defined in terms of a Volk unified by a common language, history and culture.” The proposed routes for German identity were varying.
The first chancellor of West Germany, Konrad Adenaur, in turning away from Germany’s nationalist past championed the idea that Germany was an European rather than a national entity. The European stance was also taken up by Kohl in order to reassure France and Britain and other European powers on the eve of unification, which would have meant Germany becoming the largest state in Europe, that Germany was not a threat. The scholar, Jurgen Habermas, proposed the idea of ‘constitutional patriotism’, or ‘post-national patriotism’, which is a form of national identity along the lines of civic nationalism.
However, it fails to take into account differing political beliefs in a society as it creates universalistic principles of democracy and justice; it is also seen by some as lacking the aspect of culture so strongly associated with national identity. Finally, Deutschmark Nationalism, derived from the German’s pride of their post-war recovery was attributed to the Deutschmark. Lacking a culture and history that they could hark back at proudly the Deutschmark became an emotional and symbolic issue.
This however was seen as a threat to European Integration because it meant less Germans might have been willing to surrender to the euro. This form of nationalism, although ostensibly an economic attachment to the state, and therefore civic, concealed elements of a shared culture, history and past; of the past preceding the division of Germany.
Unlike the UK, Germany’s expression of national pride, be it in terms of nationalism or patriotism, has been somewhat hindered by its brutal and recent legacy of the Holocaust and WW2. Mary Fulbrook claims that “in the shadow of the holocaust any notion of German national identity was uniquely problematic, uniquely tortured.
They could not even be ‘patriotic’ without arousing hackles and fear among their neighbours.” Public opinon polls taken in the 1950s by the allies showed a perhaps shocking reality: In 1945 in the US zone 53% of Germans thought Nazism was a good idea. In 1947 55% believed it to have been a good idea despite the fact that this was following the Nurenberg trials. In the 1950s over 50% of Germans believed Hitelr was the greatest statesman ever.
At this point it is clear that Germany had not come to terms with its Nazi past. However as time went by national sentiment does seem to have changed. In the 1980s European opinion polls where only 21% of Germans expressed pride in being German, compared to 53% of the British.
The Following table compares German attitudes towards immigrants before and after reunification:
should only marry their ethnic group
should be sent back
should be denied political activity
should adapt lifestyle of German standards
This table suggests that although the trend is towards a more multicultural Germany, there are still significant amounts of the population who believe in ethnicity and see it as an important citizenship concept. With this information in mind it is not surprising that Germans would have a complicated view towards the EU and the concessions this implies with regard to immigration. This suggests that although Germany seems to be moving towards a more civic concept of nationhood there are nevertheless significant elements of ethnic self-understanding.
The UK’s National Identity
Despite both the UK and Germany having a brutal legacy in the form of imperialism the UK has not gone through any sort of atonement. This essay does not equate the particular atrocities committed by the Germans in WW2 namely the holocaust with those of the UK‘s Imperialism but there is a significant lack of owning up to the past in the UK. It is interesting to see that institutions of the British Empire are still around today, such as, the granting of the Order of the British Empire, OBE.
The political elites have also been known to hark back to it as Gordon Brown did when speaking at the British Museum about a collection of looted treasures from Britain’s former colonies “we should be proud…of the British Empire.” When the Cambridge historian Richard Drayton talks of the reputation of the British Empire he states that: “We hear a lot about the rule of law, incorruptible government and economic progress – the reality was tyranny, oppression, poverty and the unnecessary deaths of countless millions of human beings.”  This shows a rather inward looking mentality. Of course there was little outside pressure to apologise for the wrongs committed during the period of Empire, as they did not take place locally and many other European countries had colonies.
The UK, despite its Citizenship, being officially British is still very much a divided land. The regions it comprises of; Scotland, Wales, England and Northern Ireland all define their national identity in very different terms. Anyone can become a civic British person but the Regional Identities of Welsh, Northern Irish, Scottish and English seem to be very much rooted in ethno-cultural terms. Arguably this has come about because the reality of their independence faded away long ago and in order to keep this idea alive it is necessary to look to the past in which it was a reality.
The 1.5 million people of Northern Ireland have even more complex issues surrounding nationality and citizenship: “around 2/3rd of Protestants say they think of themselves as British, and about the same proportion of Catholics say they are Irish. The numbers of Protestants supporting nationalist parties and Catholic Unionist parties are exceedingly small.”
The English often refer to themselves as British, a constant reminder of what was England’s hegemony over the rest of the British Isles. But Krishan Kunmar suggests that it “tells of the difficulty that most English people have in distinguishing themselves, in a collective way, from the other inhabitants of the British Isles.”
There is also, of course, the matter of ethnic minorities and how they relate to this diversity of national, regional and state identities. The 1997 Policy Studies Institute survey of ethnic minorities in Britain concluded ethnic minority groups are more likely to think of themselves in ethnic terms rather than Being British:
“the [ethnic] minorities were not…comfortable with the idea of British being anything more than a legal title; in particular they found it difficult to think of themselves as British because they felt the majority of white people did not accept them as British because of their race and cultural background.”
Prior to the 1981 Nationality Act, Britishness was an essentially non-national form of political identity well suited to the imperial state. It was not until the 1960s and 1970s, in order to control immigration, that the more ethnic definition of Britishness emerged and climaxed in the law of blood being introduced into Citizenship law.
Most British citizens have dual nationality. A UNESCO report on British National Identity and its attitude towards immigration looked at the ways in which a slice of the population regarded the most important factors defining ones Britishness. The results are in the table below:
Table 1: Importance of Different Aspects of ‘Being British’
Respondents answering very or fairly important (%)
Born in Britain